Time to Save Our Seas

Time for action: Save our seabed

Welsh Scallop fishery consultation

Cardigan Bay, on the west coast of Wales, is an important area for scallops. It is also an important area for wildlife, with a large Special Area of Conservation (SAC). Click the What You Can Do tab to Take Action Now or download our template response here. Thank You.

Current government management measures for scallops within the protected site in Cardigan Bay (Cardigan Bay SAC) allow only one area within the SAC being opened for a limited time each year for scallop dredging. These measures came into force in 2010 and were based on the limited evidence available at the time of inception. Welsh Government has now stated that it aims to establish a viable and sustainable scallop fishery within the currently closed area within Cardigan Bay SAC.

The Minister for Natural Resources has launched a consultation entitled ‘Proposed New Management Measures for the Scallop Fishery in Cardigan Bay’.

The Welsh Government had suspended the consultation due to technical glitches with the online form. This has now been resolved and the consultation has been reopened with a closing date of the 17th Feb 2016. All responses already submitted using the original method should be resubmitted in case they weren’t received as intended.

On the 26th November 2015 the Minister for Natural Resources, Carl Sargeant relaunched a Welsh Government consultation entitled “Proposed New Management Measures for the Scallop Fishery in Cardigan Bay”.

Cast your minds back to the winter of 2008/2009, at this time if you were to look out to sea at night you may have seen a myriad of shining lights on the horizon – these were the lights from fishing boats, fishing for scallops.

Fishing boat and fishery patrol

At that time the fishing was reportedly good and there was an influx of vessels into Cardigan Bay from all around the UK and further afield all wanting to take advantage of a good thing!

Following this, concerns were raised over the amount of dredging taking place and the impact on the features of the Special Area of Conservation (SAC). This led to the closure of all Welsh territorial waters to scallop dredging in 2009.

In 2010 the Welsh Government introduced a new piece of legislation, opening up an area of sea within the Cardigan Bay SAC within which scallop dredging was allowed to once again take place. This area is commonly referred to as the “Kaiser box” and allows a restricted fishery to occur on a seasonal basis which continues to date.

Parts of Cardigan Bay are designated as Special Areas of Conservation (SACs), Cardigan Bay Sac and Pen Llyn a’r Sarnau SAC. Cardigan Bay SAC is designated for its population of bottlenose dolphins, its sandbanks, reefs and sea caves, which are of European importance. The Wildlife Trust of South and West Wales are particularly concerned about the potential impact on the features of the site as well as the effect across the whole of the SAC including the long term impact on the marine ecosystem.

It is well documented that the process of dredging can alter the seabed habitat and diversity through the movement and disturbance of the seabed (Dayton et al 1995, Kaiser et al., 1996).

Newhaven scallop dredger

Fishing for scallops with the toothed Newhaven dredges commonly used around the United Kingdom (UK) has been considered one of the most damaging of all fishing gears to non-target benthic communities and habitats (Kaiser et al., 2006). Changes to the physical structure of the seabed can occur (Collie et al., 2000) as well as changes to the seabed community structure (Dayton et al., 1995).

Larger sediment, such as cobbles, are picked up and brought to the surface in the dredge itself and discarded away from source. Other impacts include sediment compaction, and chemical changes caused by the disturbance of the seabed (Sciberras et al., 2013).

Dredges can damage reef structures and other vulnerable seabed habitats and features as well as impacting non-target species. The long-term impact on the marine ecosystem as a whole, including all species, in particular species further up the food chain is largely unknown.

Pink Sea Fan Paul Naylor

The current consultation includes the Welsh Government’s recommendations for the establishment of a viable and sustainable scallop fishery within the Cardigan Bay SAC.

There has been little or no pre-consultation engagement with wider stakeholders other than representatives from Natural Resources Wales (NRW) scientists (it is not clear which scientists were consulted with), and industry representatives.

No conservation organisations were involved. The Welsh Government proposals include the introduction of a scallop permit scheme allowing those with a permit to dredge for scallops anywhere in the Cardigan Bay area within the 3 to 12 nautical mile zone, subject to certain conditions that would be applied on an annual basis.

These recommendations are based on a study conducted in the Cardigan Bay SAC, undertaken by Bangor University in collaboration with the industry during 2014 and early 2015. This study investigated the impact that scallop dredging may have on the SAC and its wildlife. However, this study fails to take into account the fact that the seabed has already been damaged by previous dredging activity.

Until 2010, over two thirds of the Cardigan Bay SAC were open to scallop dredging, creating modified seabed habitats throughout the whole of Cardigan Bay. Using a previously dredged area of the SAC as a baseline is not adequate justification for permitting further damaging activity; a more appropriate control would have been a pristine area of seabed.

The Cardigan Bay SAC is in an unfavourable condition with the protected features in a degraded state. It is unclear why the Welsh Government is considering opening up additional areas within Cardigan Bay to a damaging activity which could prevent the site from recovering, a requirement by both national and international legislation, without robust scientific evidence to suggest there would be no adverse effect on the area.

There are concerns that the potential effect of the fishing activity and the impacts of this on other economic activities within Cardigan Bay have not been considered.

Tourism brings far more money into the coastal economy than the fishing industry, a clean and healthy marine and coastal environment is fundamental for the future of coastal communities and therefore coastal tourism. In 2009 visitors (i.e. tourists) to Wales contributed £6.18bn (13.3% of Welsh GDP) (Wales Tourism Definitive Value report (2012).

In 2013 Dolphin watching in New Quay and the associated tourism activities contributed at least £4.9million to Ceredigion alone. The tourism sector is an industry based on many services and therefore the impact on the employment sector (such as agriculture, construction and hospitality) could be wide ranging. (Garcia Hernandez, 2015).

In Pembrokeshire studies have shown that total expenditure associated with tourism marine activities in St David’s was estimated at £51.4mn per annum, this equates to a contribution to the Welsh economy in terms of Gross Value Added (GVA) of approx. £24.5mn per annum. The largest contributor is beach activities followed by walking and wildlife boat trips (Wales Activity Mapping, 2013).

The Welsh Government must consider additional scientific evidence and provide robust scientific evidence to demonstrate that additional scallop dredging activity in Cardigan Bay will not have an adverse effect, in the short or long term, on any of the features of the SAC.

The Wildlife Trust of South and West Wales are in the process of finalising our own formal response to this consultation.

However, we are aware that our members are keen to respond to the consultation and therefore we have created a draft response letter to assist those wishing to respond outlining the main concerns.

We urge you to voice your own concerns; its very important that you personalise your response to ensure it is considered as a single response rather than a campaign response. It is also a good idea to word your response so that it cannot be misinterpreted. We hope that the information above will help you, should you wish to do this.

Please write directly to Welsh Government and send your letter in either by:
Email: fisheriesmailbox@Wales.gsi.gov.uk

Please note that Welsh Government intends to publish the responses received. This includes publishing the name and address of the person or organisation that sent the response. If you do not want your name or address published then you must notify Welsh Government of this in writing. We suggest writing that you do not wish your personal data (name or address) to be published under any circumstances, clearly at the top of your letter of response.

We advise those wishing to respond to write directly to the Welsh Government, rather than use the online response form provided by the Welsh Government. The consultation is due to close on the 17th February 2016 and we strongly urge you to voice your opinions; have your say and respond to this consultation.

CCW (2009). Cardigan Bay European Maine Site Advice provided by the Countryside Council for Wales on fulfilment of regulation 33 of the conservation (Natural Habitats, &c). Regulations 1994, February 2009.